AML / KYC Statement

This statement describes TrafficSigma’s approach to anti-money-laundering ("AML"), counter-terrorist-financing ("CTF"), sanctions compliance, and know-your-customer ("KYC") due diligence in relation to advertiser deposits, publisher payouts, and account onboarding.

Scope note. TrafficSigma is an advertising technology business, not a bank, payment institution, or money-services business, and this statement is not a representation that we are licensed or supervised as a financial institution. The precise legal AML/CTF obligations that apply to us depend on our operating entity and jurisdiction: [APPLICABLE AML/CTF REGIME, SUPERVISORY AUTHORITY (IF ANY), AND REGISTRATION STATUS TO BE CONFIRMED BY QUALIFIED COUNSEL.] Where we are not directly regulated, the controls below are applied as a matter of policy and risk management, and we rely additionally on the regulated payment providers, acquirers, and exchanges that process funds for us.

1. Our commitment

We do not tolerate the use of our platform to launder criminal proceeds, finance terrorism, evade sanctions, or disguise the source or destination of funds. We apply a risk-based approach: the depth of due diligence and monitoring is proportionate to the risk presented by the customer, the geography, the payment method, and the transaction pattern.

2. Customer due diligence (KYC)

Depending on risk, we may collect and verify:

• For individuals: full name, date of birth, residential address, a government-issued photo identity document, and, where needed, proof of address and a liveness or selfie check.
• For legal entities: legal name, registration number, registered address, certificate of incorporation or an equivalent registry extract, ownership and control structure, identification of beneficial owners holding a qualifying interest, and identification of directors and authorized signatories.
• For all customers: the payment instrument used, evidence that the customer controls it, the nature of the business and the verticals promoted, and, where relevant, source of funds or source of wealth information.

We may refuse to open an account, refuse a deposit, or decline a payout where required information is not provided, cannot be verified, or is inconsistent with other information we hold.

3. When verification is triggered

Verification may be requested at onboarding or later, including where:

• Deposit or payout volumes exceed internal risk thresholds, in aggregate or in a single transaction.
• Payment methods are changed, or funds are received from or requested to a third party not matching the account holder.
• The account, its beneficial owners, or its counterparties present sanctions, adverse-media, or politically-exposed-person indicators.
• Activity is inconsistent with the stated business profile, or the account shows structuring or rapid deposit-and-withdrawal patterns.
• A payment provider, acquirer, bank, or competent authority requests information.
• The account is linked to a geography subject to enhanced risk or to restrictive measures.

4. Sanctions and restricted geographies

We screen customers and beneficial owners against applicable sanctions and restrictive-measures lists, and we do not knowingly onboard or transact with sanctioned persons or entities, or with customers located in comprehensively sanctioned territories. Screening is repeated periodically and on material account changes. A confirmed match results in the account being blocked and, where required, the matter being reported and any funds frozen in line with the applicable legal obligation.

5. Ongoing monitoring

We monitor account and transaction activity on a risk basis for patterns that may indicate money laundering, terrorist financing, sanctions evasion, or fraud - for example rapid deposits followed by refund requests, mismatches between deposits and actual media spend, use of multiple unrelated payment instruments, and coordinated behaviour across linked accounts. Alerts are reviewed by our compliance function and escalated where warranted.

6. Prohibited financial conduct

• Using advertiser balances as a store of value or a transfer mechanism rather than to purchase advertising.
• Depositing from, or requesting payout to, an account that does not belong to the verified account holder.
• Structuring transactions to fall below verification or reporting thresholds.
• Providing false, altered, or stolen identity or company documents.
• Refund-cycling, chargeback abuse, or using our platform to convert funds between payment rails.

7. Reporting and cooperation

Where we identify activity we suspect relates to money laundering, terrorist financing, sanctions evasion, or other financial crime, we escalate internally and, where a legal obligation applies to us or our providers, submit the required report to the competent authority. We cooperate with lawful requests from authorities, payment providers, and financial institutions. Where the law prohibits it, we will not tip off a customer that a report has been made.

8. Record keeping

Identification data, verification evidence, and transaction records are retained for the period required by applicable law - commonly at least five years after the end of the customer relationship or the transaction - and are then deleted or anonymized. Retention and handling of this personal data are governed by our Privacy Policy.

9. Governance and training

Responsibility for this statement sits with our compliance function, which reviews it at least annually and on material regulatory change. Relevant staff receive training appropriate to their role on AML/CTF and sanctions risk indicators and on escalation procedures.

10. Consequences of non-compliance

Failure to complete verification, or conduct falling within Section 6, may result in suspension of the account, refusal or reversal of deposits, withholding of payouts, termination of the relationship, and, where applicable, reporting to the competent authorities. Refunds in such cases are governed by our Refund Policy.

11. Contact

Compliance queries can be sent to [email protected].